Chemical management for consumer products - Industry landscape and recommendations for progress - University of ...

 
Chemical management
for consumer products
Industry landscape and recommendations for progress
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 B

ABOUT THE AUTHORS                                               ACKNOWLEDGEMENTS
The Institute for Sustainable Futures (ISF) is an               The team that undertook this research was a partnership
interdisciplinary research and consulting organisation at the   between ISF and Ascend Waste and Environment Pty Ltd.
University of Technology Sydney setting global benchmarks
since 1997 in helping governments, organisations,               The team thanks all the companies who agreed to
businesses and communities achieve change towards               participate in the research and who took part in an
sustainable futures. We utilise a unique combination of         interview and/or provided data. We also thank the NGOs
skills and perspectives to offer long-term sustainable          and academics who helped provide perspectives as input
solutions that protect and enhance the environment,             to the research.
human well being and social equity.
                                                                DISCLAIMER
For further information visit: www.isf.uts.edu.au
                                                                This research was commissioned by a sustainable
                                                                investment company, which has been anonymised for the
RESEARCH TEAM                                                   public version of this report. The content of this report has
Prof. Damien Giurco, Jerastin Dubash,                           been prepared independently by the research team. The
Rachael Wakefield‑Rann, Emily Prentice.                         research team has used all due care and skill to ensure
Special Advisor: Geoff Latimer, Ascend Waste                    the material is accurate as at the date of publication and
and Environment Pty Ltd                                         any opinions expressed therein are those of the authors.
                                                                However, the use of the Research is at the user’s own risk
                                                                and ISF, the client and Ascend Waste and Environment
CITATION
                                                                Pty Ltd disclaim any responsibility to anyone relying upon
Please cite as: Dubash, J., Wakefield-Rann, R., Prentice,       the Research.
E., Giurco, D., and Latimer, G. (2018): Chemical
Management for Consumer Products – Industry
landscape and recommendations for progress. Institute for       INSTITUTE FOR SUSTAINABLE FUTURES
Sustainable Futures, UTS.                                       University of Technology Sydney
                                                                PO Box 123 Broadway, NSW, 2007
                                                                isf@uts.edu.au
                                                                www.isf.edu.au

                                                                © UTS November 2020
                                                                Tel: +61 2 9514 4950
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS             1

Contents
INTRODUCTION                                    1    4.     RESULTS SUMMARY                                 26
                                                     4.1    Overall score results, by company               26
EXECUTIVE SUMMARY                                3
                                                     	Figure 3: Overall score results, by company          26
Figure 1: Overall results summary                4
                                                     4.2    Overall score results, by assessment criteria   27
What does best practice look like?               7
                                                     	Figure 4: Overall score results, by
ABBREVIATIONS                                    8     assessment criteria                                  27
                                                     4.3	Ingredient disclosure and ‘Chemicals of
                                                          Concern’ grades by company                        28
THE REPORT                                      9
                                                     	Table 9: Ingredient disclosure and chemicals
1.     INTRODUCTION                             10     of concern                                           28

1.1    Research commissioned                    10   4.4    Personal Care sector                            29

	Table 1: Product categories and specific           	Table 10: Personal Care results summary              29
  products analysed                             10
                                                     4.5    Home Care sector                                30
1.2    What are chemicals of concern?           11
                                                            Table 11: Home Care results summary             30
       Table 2: Chemicals of concern            12
                                                     4.6    Paints sector                                   30
       Figure 2: Chemical classes of concern    13
                                                            Table 12: Paints results summary                30

2.	UNDERSTANDING THE REGULATORY                     4.7    Pesticides and Insecticides sector              31
    AND POLITICAL CONTEXT                       14   4.8    Adhesives and Sealants                          31
       Table 3: Regulatory overview             14   	Table 13: Adhesives and Sealants
2.1 	 Issues: developed economies               17     results summary                                      31

2.2 	 Issues: developing economies              17   4.9    Ingredients Manufacturing                       31
                                                     	Table 14: Ingredients Manufacturing
3.     EVALUATION FRAMEWORK                     20     results summary                                      31
	Table 4: Product responsibility performance
  evaluation criteria                           20   5.     RECOMMENDATIONS                                 32

	Table 5: Product responsibility evaluation         5.1    Improvement opportunities                       32
  scoring table                                 22   5.2    Build enabling networks                         34
	Table 6: Chemicals of Concern ratings                     Figure 5: Connections between NGOs              34
  and descriptions                              23
                                                     5.3    Future research areas                           35
	Table 7: Levels of Ingredient Disclosure
  ratings and descriptions                      24
	Table 8: Regulatory, Reputational and
  Financial risk references                     25
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS   2

Executive Summary
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS   3

Executive Summary

This report seeks to understand best and worst practice in relation to product safety
standards and the use and management of potentially hazardous chemicals in products,
with a special focus on consumer products in established and emerging markets across
the globe. The report explores what constitutes leading practice in product safety
standards and collates the efforts of selected companies to remove or avoid potentially
hazardous chemicals in their products. Whilst individual companies are not uniquely
identified, collectively the work paints a picture of the state-of-play.

The research focused on the following

                                               1|   REVIEW OF PUBLICLY
product categories:
                                                    AVAILABLE DOCUMENTS
• Personal Care products (including
  cosmetics, oral care, hair care,
  sunscreens, soaps and skin creams)
• Home Care products (laundry, cleaning
  and air fresheners)
• Pesticides and Insecticides (for home
                                               2|    NLINE BASELINE SURVEY
                                                    O
                                                    COMPLETED BY COMPANIES IN
                                                    RELATION TO CURRENT PRACTICES
  use only)
• Paints (for home use)
• Adhesives and Sealants (for home use)

                                               3|
• Ingredients manufactured for these
                                                     HONE INTERVIEW OR WRITTEN
                                                    P
  sectors.
                                                    RESPONSE WITH COMPANIES IN
The data collection process is illustrated          RELATION TO CURRENT PRACTICES
to the right.

                                               4|    XPERT INTERVIEWS (NGOS,
                                                    E
                                                    ACADEMICS) TO ASCERTAIN GLOBAL
                                                    CONTEXT, BEST PRACTICE

                                               5|   EVALUATION OF COMPANY PRODUCT
                                                    RESPONSIBILITY EFFORTS
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 4

Executive Summary continued

The research began by gathering publicly available information about the 21 companies reviewed in this report, and
proceeded with gathering publicly available information about these companies. ISF also contacted the companies to complete
a ‘baseline survey’ in relation to their current practices on the use and management of hazardous chemicals in their products,
and a phone interview or written response to more detailed questions. This information was supplemented with interviews with
six NGOs and academics active in the field of product responsibility and/or the consumer products sector.

In order to keep the included companies anonymous, we have identified each with the initial ‘C’, and assigned them a number
from 1 to 21.

RESULTS SUMMARY
Figure 1: Overall results summary

                    C9 (Ingredients)
       C16 (Adhesives and Sealants)
 C2 (Paints, Adhesives and Sealants)
C10 (Paints, Adhesives and Sealants)
      C4 (Personal Care, Home Care)
                  C3 (Personal Care)
      C5 (Personal Care, Home Care,
        Pesticides and Insecticides)
                   C18 (Ingredients)
                  C1 (Personal Care)
                       C11 (Paints)
                       C15 (Paints)
                C12 (Personal Care)
    C20 (Personal Care, Ingredients)
      C8 (Personal Care, Home Care)
                       C19 (Paints)
                C14 (Personal Care)
      C6 (Personal Care, Home Care,
        Pesticides and Insecticides)
    C17 (Personal Care, Home Care)
      C7 (Personal Care, Home Care,
Adhesives and Sealants, Ingredients)
    C13 (Personal Care, Home Care)
    C21 (Personal Care, Home Care)

                                                   1                   2                 3                 4                   5
                                               No Action        Getting Started     Established         Leading          Best Practice

Figure 1 ranks the companies in order from least to highest average score calculated across the criteria categories, with the
circles representing the average and ‘lozenges’ representing the range of scores achieved across all criteria. All company
performance evaluations were at or below ‘Established’ level. Nine companies were evaluated as ‘Getting Started’ level with
another eight companies evaluated as ‘No Action’. This indicates that there is much progress to be made in moving towards
safe, sustainable and responsible management of chemicals in consumer products across these companies.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS               5

RESEARCH HIGHLIGHTS
Hazardous ingredient responsibility and its relationship to company sustainability
were not well considered by the majority of companies
In interview and written company responses, there was little acknowledgement of the significance of proactive and
precautionary chemical management policies for long-term human and environmental health. Rather, company responses
tended to frame ‘sustainability’ in terms of water and energy usage and waste generation. As one NGO interviewed stated
“companies do not consider product ingredients and altering them at the core of achieving true sustainability […] if product
ingredients are changed, only then can overall company sustainability be improved”.

  i   I MPLICATIONS: Greater corporate focus is required to integrate responsible ingredient sourcing and hazardous
       chemicals management with the precautionary principle and overall sustainability goals to achieve genuine long-term
       sustainability, in terms of environmental, human health and business outcomes.

Disclosure of product ingredients is generally poor
Seven of the 21 companies received a ‘Good’ rating for ingredient disclosure. Evaluating companies on their product
responsibility efforts was challenging given the lack of substantial and explicit information in public documents, and
companies’ efforts to protect ‘trade secrets’. It was often a challenge for investor relations teams to identify appropriate staff
within the company to respond to our queries.

  i   I MPLICATIONS: Consumers are increasingly demanding transparency and the power to decide what ingredients
       they consume. Given inadequate chemical testing and the continued inclusion of concerning chemicals in consumer
       products, there is an urgent need for product ingredient disclosure across product sectors to be improved.

Some sectors fared worse than others
The best overall scores in company evaluations for responsible chemical management in consumer products were for the
Personal Care and Home Care sectors. The Paints sector came in second, followed by generally poor performance across
the Adhesives and Sealants and Ingredients Manufacturing sectors. The Pesticides and Insecticides sector had only two
representative companies and could not be comprehensively evaluated. Despite the higher toxicity of products in the
Pesticides and Insecticides and the Adhesives and Sealants categories, and the requirement for manufacturers to provide
Material Safety Data Sheets (MSDS), these health and safety documents generally focus on handling issues and immediate
first aid concerns rather than information about ingredient toxicity and bio-accumulative impacts in the long-term.

Particular ingredients of concern featured prominently
Microbeads, triclosan, parabens, generically termed ‘fragrance’ or ‘parfum’, DMDM hydantoin and phthalates were some of
the main ingredients of concern among the Personal Care and Home Care segments. Volatile organic compounds (toluene,
ethylbenzene) and lead were the main concerns in the Paints and Adhesives and Sealants segments.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                6

Executive Summary continued

 i    I MPLICATIONS: All of these ingredients are of moderate to high concern on the Environmental Working Group’s ‘Skin
       Deep’ Database and ChemSec’s SIN List, and are recommended for elimination. The continued use of these chemicals
       is likely to result in increased regulatory and/or reputational risks. Products containing these ingredients should be
       reformulated or redesigned to exclude these ingredients of concern, and other chemicals within the six chemical classes
       of particular concern to avoid ‘regrettable substitution’ issues (see Section 2.3.3)

No difference between developed and developing countries was evident in terms of
proactive chemical management practices
Indian companies showed leadership in responsible chemicals management by either self-imposing EU REACH product
responsibility/safety norms or were guided by the Bureau of Indian Standards, despite weak domestic regulations and policies.
In particular, Indian paint companies led the pack by removing lead and/or reducing Volatile Organic Compounds (VOC) in
their paint products. One company based in Brazil, mentioned that though their own domestic regulation was not stringent,
the neighbouring market of Chile had very strict product regulation with respect to particular chemicals, which influenced their
product reformulations to continue supplying this market.

Few companies were able to provide evidence of appropriate risk assessments of products,
including life cycle assessments
While some companies have clear commitments to life cycle assessment of their products, others provided little to no evidence
that any risk assessment is being undertaken on a regular basis, or at least as part of the product development process. Lee
Bell from IPEN also noted, in an interview, the inadequacy of traditional risk assessment methods, as they cannot account
for complex use scenarios in which different chemical combinations result in different forms of harm over time. Given that a
number of companies have faced public scrutiny in relation to consumer products in recent years, it is unclear why life cycle
assessments are not integrated into regular risk assessment accounting for multiple use scenarios, and reporting to ensure
safety, environmental, reputational and financial risk is appropriately managed.

 i    I MPLICATIONS: The continued use of chemicals that have not undergone rigorous testing for multiple use scenarios
       and long term human health and environmental impacts poses a significant risk to companies. Many of the companies
       assessed would consequently benefit from implementing a thorough risk assessment process, including potential long
       term impacts and a detailed Life Cycle Assessment.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS         7

What does best practice look like?
From the interviews, written responses and public documents reviewed, ISF has developed the following recommendations
for companies that want to lead in the product responsibility/ chemical management space:

  1
          Adopt a precautionary approach to chemical management across the product development process and supply
          chain monitoring for ALL products - not just for the select few products branded as ‘eco’ or ‘green’.

  2
          Question the necessity of using potentially hazardous chemicals when designing both products and
          their packaging.

  3
          Adopt a precautionary principle when redesigning or reformulating products that currently contain potentially
          hazardous chemicals.

  4       Fully and explicitly disclose all ingredients on product labels, avoiding generic terms.

  5
          Engage with stakeholders more widely, including multipartite consultations and international roundtables, with
          governments, NGOs, academics, waste and recycling managers, product users and industry product designers.

  6
          Engage with other companies with proactive chemical management and corporate strategies. For example, IKEA,
          Apple, Boots, Skanska and H&M are members of ChemSec’s Business Group.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS   8

Abbreviations

AICS       Australian Inventory of Chemical Substances

BCRC       Basel Convention Regional Centre for the Asia and Pacific Region in China

BIS        Bureau of Indian Standards

Cefic      The European Chemical Industry Council

ChemSec    International Chemical Secretariat

EDC        Endocrine Disrupting Chemicals

EMS        Environmental Management System

EWG        Environmental Working Group

IFRA       International Fragrance Association

IPEN       International Persistent Organic Pollutants Elimination Network

JIS        Japan Industrial Standard

K-REACH    Korean Safety and Labelling Standards for Chemical Consumer Products

LCA        Life Cycle Assessment

MSDS       Material Safety Data Sheet

NPI        National Pollutant Inventory

POP        Persistent Organic Pollutant

REACH      Europe’s Registration, Evaluation, Authorisation and Restriction of Chemicals policy

RSL        Restricted Substance List

SDS        Safety Data Sheet

SIN List   ChemSec’s Substitute It Now! List

TIS        Together for Sustainability Initiative

VOC        Volatile Organic Compound
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS   9

The report
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS               10

1. Introduction

1.1 Research
This report seeks to understand best and worst practice in product chemical safety standards for companies in the consumer
products sector in developed and developing countries. This research report seeks to:

  1
          Identify which companies amongst those evaluated have gone furthest to proactively remove potentially hazardous
           chemicals from their products and which are doing just enough to keep up with regulation;

  2
           rovide a comprehensive evaluation of which companies are at greatest reputational, financial and regulatory risk
          P
          from rising consumer awareness around toxic ingredients and tightening state regulatory standards;

  3
          Identify for each company in the study (21 companies) key actions that senior management should undertake
           over the short-term (less than 3 years) and long-term, to further de-risk their businesses.

This research focuses on the following consumer product categories, with some specific analysis conducted on ingredients in
products within the category.

Table 1: Product categories and specific products analysed

 Sector             Specific products analysed

 Personal Care      Sunscreens, body lotions, moisturisers, make-up and cosmetics, body wash, hand wash, soaps,
                    perfumes, deodorants, talcum powders, baby care products, hair dyes, shampoos, conditioners, hair
                    sprays and other hair styling products, skin and hair bleaches, hair removal products, toothpastes and
                    tooth powders.

 Home Care          Laundry powders and detergents, dishwashing detergents, tablets and powders, home cleaning
                    products, air fresheners and deodorising sprays.

 Pesticides         Insect repellent sprays and lotions (for body), indoor pest control sprays, coils, electric and non-electric
 and                kits, outdoor insect control sprays, powders or pellets.
 Insecticides

 Paints             Interior paints, exterior paints, undercoatings and primers for consumer use.

 Adhesives and      Enamels, epoxies, stains and finishes for wood and metals, waterproofing solutions, tile adhesives and
 Sealants           grouts, craft and hobby adhesives, adhesive tapes for consumer use.

 Ingredients        Fragrances used in the manufacture of Personal Care and Home Care products.

These product categories were selected to focus the scope of the research on the analysis of products that have the most
direct impact on human health and indoor environments through contact with skin, hair, eyes, or through ingestion. There
are other consumer product categories such as food and food packaging, furniture and household goods, which also
contain chemicals of concern, however, analysis of these product categories are outside the scope of this project and are
recommended for review in subsequent research projects.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                      11

1.2 What are chemicals of concern?
The number of chemicals registered for use in consumer products around the world exceeds 80,000, and approximately
2,000 new chemicals enter the market each year, the majority of which have never been tested.1 This means that there is
insufficient research on many of the chemicals in consumer products.

Traditionally, chemical regulation around the world has placed the burden of proof of harm on consumers and scientists.
Within this regulatory framework, a chemical is considered safe until it is proven otherwise. Even in instances where research
is funded to conduct testing, conventional toxicological risk assessments – based on testing single chemicals on animals in a
laboratory setting – are only able to capture short-term harm with consistent physiological effects. They are not able to account
for long-term impacts, such as cancer and hormonal disruption, or the impacts of chemicals in complex everyday use-
scenarios where people or ecosystems are exposed to multiple chemicals at the same time.

However, the regulatory landscape is shifting to make producers of chemicals and consumer products more responsible.
ISF has explored this regulatory shift in more detail in Section 2 of this Report.

Until now, there have been few incentives for companies to implement a rigorous, proactive chemical management plan.
However, as regulations become stricter and consumers become more aware of chemical risks posed by consumer
products, it will be necessary for companies to engage with emerging science and adopt a more precautionary approach
to chemical safety.

To outline some of the effects associated with certain chemical ingredients, we have developed a guide below to describe
some of the most commonly encountered chemicals, included in many of the products listed in Table 1. Table 2 provides an
overview of some of the most controversial chemicals that have gained political and consumer attention around the world.
There are many more chemicals of concern not listed here, however, those listed have been identified as posing the greatest
potential reputational risk.

        Endocrine disrupting chemicals                           Chemicals that accumulate                       Carcinogenic refers to
        (EDCs) interfere with the normal                           in living organisms, so                      substances that have the
      functioning of the hormonal system.                         that their concentrations                     potential to cause cancer.
       They have been linked to impaired                          in body tissues continue
     development of reproductive, immune                           to increase, are called
       and neurological systems, certain                             bioaccumulative.3
         cancers, obesity and diabetes.2

1 Ha, S., Seidle, T., & Lim, K. M. (2016). Act on the Registration and Evaluation of Chemicals (K-REACH) and replacement, reduction or refinement
  best practices. Environmental health and toxicology, 31.
2 US EPA Website. “What are Concerns Regarding Endocrine Disruptors?”, https://www.epa.gov/endocrine-disruption/what-endocrine-disruption
3 Safer Chemicals, Healthy Families Website. http://saferchemicals.org/get-the-facts/chemicals-of-concern/persistent-bioaccumulative-and-toxic-
  chemicals-pbts/
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                     12

1. Introduction continued

Considering the inadequacy of current chemical testing requirements, scientists are increasingly advocating for the restricted
use of entire chemical classes. Table 2 provides a list of six chemical classes that have been recommended for exclusion from
consumer products.4 These six classes contain chemicals known to cause harm to humans and the environment, and closely
related chemicals that have not yet been tested but are suspected to be harmful. Restricting a class of chemicals avoids a
specific chemical of concern being substituted by one which is functionally similar but inadequately tested.

  i    AS AN INVESTOR, asking questions about which chemical classes are present in products would be a helpful step in
       understanding a company’s ingredient disclosure policies and product development process.
       

Table 2: Chemicals of concern

  Volatile Organic Compounds           Respiratory irritant, central nervous system effects
  (toluene, ethylbenzene,              Present in: Paints, Home Care products, Personal Care products, Adhesives and
  xylene)                              Sealants, Pesticides and Insecticides

  Triclocarban/ Triclosan              Endocrine disruption, environmental toxicant, bioaccumulative
                                       Present in: Personal Care products, Home Care products

  Formaldehyde                         Carcinogenic, organ system toxicant, allergen, environmental toxicant
                                       Present in: Personal Care products, Paints

  Fragrance                            Immune system toxicant, environmental toxicant
                                       Present in: Personal Care products, Home Care products

  Lead                                 Brain and central nervous system developmental effects
                                       Present in: Paints

  Nanoparticles                        Unknown effects, extremely reactive/catalytic
                                       Present in: Personal Care products, Paints

  Titanium dioxide                     Brain and central nervous system effects, carcinogenic
                                       Present in: Personal Care products, Paints

  Polybrominated Diphenyl              Flame retardant has links to tumours, neurodevelopmental toxicity and thyroid hormone
  Ethers (PBDE)                        imbalance, endocrine disruption
                                       Present in: Paints

  Per- and poly-fluoroalkyl            Possibly carcinogenic, bioaccumulative environmental toxicant, endocrine disruption,
  substances (PFASs)                   neurotoxicity
                                       Present in: Personal Care products, Home Care products, Adhesives and Sealants

  Pthalates                            Endocrine disruption, bioaccumulative environmental toxicant
                                       Present in: Personal Care products, Adhesives and Sealants

4 The Six Classes Approach to Reducing Chemical Harm. Green Science Policy Institute, http://www.sixclasses.org [accessed 22nd December 2017]
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS             13

Figure 2: Chemical classes of concern5

                                                        HIGHLY
                                                     FLUORINATED
                                                        (PFASS)
                                                         PFOA, PFOS,
                                                      Other 3000 related
                                                          compounds

                                                                                             CHLORINATED
        CERTAIN METALS                                                                      ANTI-MICROBIALS
           Mercury, Cadmium,                                                                  Triclosan, Triclocarban,
                 Lead                                                                         Nanosilver, Quaternary
                                                                                                 ammonium salts,
                                                                                              Benzalkonium Chloride

                                                             6
                                                       CHEMICAL
                                                      CLASSES OF
                                                       CONCERN

        SOME SOLVENTS                                                                              FLAME
                                                                                                RETARDANTS
         VOCs (toluene, xylene,
         benzene), Halogenated                                                                  PBDEs, Chlorinated
            organic solvents                                                                      Tris (TDCPP)

                                                     BISPHENOLS
                                                     & PTHALATES
                                                Bisphenol A (BPA), Bisphenol
                                                 S (BPS), Bisphenol F (BPF),
                                                Dibutyl Pthalate, Butyl Benzyl
                                                 Pthalate, Dimethyl Pthalate,
                                                       Diethyl Pthalate

5 As adapted from the Green Science Policy Institute ‘SixClasses.Org’ Website, http://www.sixclasses.org/ [accessed 22nd December 2017]
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS            14

2. Understanding the regulatory
    and political context
A number of challenges have prevented adequate regulation to protect humans and the environment from hazardous
chemicals in both developed and developing countries. A brief list of chemicals management regulations, policies, standards
and agreements is shown in the table below.

Table 3: Regulatory overview

 Country/           Regulation/policy/
 Region             agreement/standard           Description

 Global             United Nations               CiP aims to reduce risks from hazardous chemicals in products through
                    Environment Programme        3 key objectives:
                    Chemicals in Products
                    (CiP) Programme              • To know and exchange information on chemicals in products,
                                                   associated hazards and sound management practices within supply
                                                   chains;
                                                 • To disclose information of relevance to stakeholders outside the supply
                                                   chain to enable informed decision-making and actions about chemicals
                                                   in consumer products;
                                                 • To ensure that, through due diligence, information is accurate, current
                                                   and accessible.

                    Globally Harmonised          1. P
                                                     rovides harmonized criteria for classifying substances and mixtures
                    System of classifying and       according to their health, environmental and physical hazards, and;
                    labelling chemicals (GHS)    2. Provides harmonised hazard communication elements, including
                                                     requirements for labelling and safety data sheets.

 Multilateral       Stockholm Convention         Objective: to prohibit and/or eliminate the production and use, as well as
                                                 the import and export, of intentionally produced POPs. (Persistent Organic
                                                 Pollutants (POPs): chemicals that remain intact in the environment for
                                                 long periods, become widely distributed geographically, accumulate in the
                                                 fatty tissue of humans and wildlife, and have harmful impacts on human
                                                 health or on the environment.)

                    Rotterdam Convention         Objective: create legally binding obligations for the international trade
                                                 of hazardous chemicals, and the environmentally sound use of those
                                                 hazardous chemicals. It primarily covers pesticides and industrial
                                                 chemicals.

                    Basel Convention             Objective: promote the reduction of hazardous waste generation, the
                                                 sound management of hazardous wastes, the restriction of transboundary
                                                 movements of hazardous wastes, and regulatory systems in cases where
                                                 transboundary movements are permissible.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                  15

  Country/            Regulation/policy/
  Region              agreement/standard               Description

  Europe              REACH                            • The European Union’s REACH (Registration, Evaluation, Authorisation
                                                         and Restriction of Chemicals) program is recognised as the most
                                                         comprehensive regional regulatory framework6.
                                                       • REACH operates based on four processes: the registration, evaluation,
                                                         authorisation and restriction of chemicals.
                                                       • It shifts the responsibility from public authorities to industry for
                                                         assessing risks and providing appropriate safety information for
                                                         chemical use.
                                                       • 524 chemicals to date are restricted under REACH are listed in Annex XVII.
                                                         A further 204 chemicals are listed as ‘substances of very high concern’.

  United States       EPA Toxic Substances             • Inventory of existing chemical substances in the USA.
  of America          Control Act (TSCA)               • If a chemical is not on the inventory, it is considered a ‘new chemical
                      Chemical Substance                 substance’ and must be reviewed under the EPA’s TSCA New Chemicals
                      Inventory                          Review Program, which acts as a gatekeeper that can identify conditions,
                                                         up to and including a ban on production, to be placed on the use of a
                                                         new chemical before it is entered into commerce.
                                                       • https://www.epa.gov/tsca-inventory.

  Australia           NICNAS Australian                • Assesses the risks of industrial chemicals and provides information to
                      Inventory of Chemical              promote their safe use.
                      Substances (AICS)                • Focuses on chemicals used in inks, plastics, adhesives, paints, glues,
                                                         solvents, cosmetics, soaps and many other products.
                                                       • https://www.nicnas.gov.au/chemical-inventory-AICS.

                      Hazardous Chemical               • HCIS is an internet advisory service providing information on chemicals that
                      Information System                 have been classified in accordance with the Globally Harmonized System of
                      (HCIS)                             Classification and Labelling of Chemicals (GHS) by an authoritative source,
                                                         such as the European Chemicals Agency (ECHA) or the National Industrial
                                                         Chemicals Notification and Assessment Scheme (NICNAS).
                                                       • Not an exhaustive hazardous chemicals database.
                                                       • http://hcis.safeworkaustralia.gov.au/#Classification.

                      The National Pollutant           • Contains data on 93 substances that have been identified as important
                      Inventory (NPI)                    due to their possible effect on human health and the environment.
                                                       • Provides monitoring data for environmental pollutants originating from
                                                         mines, power stations and factories, and from other sources such as
                                                         households and transport.
                                                       • http://www.npi.gov.au
                                                       • http://www.npi.gov.au/resource/technical-advisory-panel-report

6 Understanding REACH: European Chemicals Agency. https://echa.europa.eu/regulations/reach/understanding-reach [Accessed 26 March 2018]
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                        16

2. Understanding the regulatory and
political context continued

 Country/              Regulation/policy/
 Region                agreement/standard                Description

 Japan                 Japan Industrial Standard         • Chemical classification, labelling and safety data sheet (SDS) regulations
                       (JIS)                               are addressed by the Japan Industrial Standard (JIS)
                                                         • Implemented a single standard in January 2017, to which all companies
                                                           must comply.
                                                         • The 1974 law on household products containing harmful substances
                                                           (2009 revision) established permissible limits of harmful substances
                                                           in household products. The list of harmful substances can be found at
                                                           Japan’s Chemical Risk Information Platform (CHRIP).

 South Korea           K-REACH                           • K-REACH Safety and Labelling Standards for Chemical Consumer
                                                           Products
                                                         • From April 2015 – safety and labelling standards for eight types of
                                                           products including: cleaning agents, synthetic detergents, bleaching
                                                           agents, fabric softeners, coatings, adhesives (including glues),
                                                           fragrances, and deodorants.
                                                         • From 1 July 2013, businesses must comply with GHS standards with
                                                           regards to mixtures classification and labelling.

 India                 National Chemical Policy          Been in draft form since 2012, further refined in 2014.
                                                         Gained support from industry and some government agencies but still
                                                         awaiting approval.7

The European Union’s chemical regulation framework REACH (Registration, Evaluation, Authorisation and Restriction of
Chemicals) is shifting the burden of proof to industries, requiring them to demonstrate that the chemicals they produce
do not cause harm.

  i     he final deadline for companies to register the old and new chemicals they want to use in products for
       T
       REACH is May 2018.

Other countries, such as China and Korea1, are following in this model, meaning that regulation around the world will
increasingly require more stringent chemical testing to be carried out by companies. Although REACH represents a step
in the right direction, concern has been raised that chemical restrictions and bans will be weakened by member states and
industries that rely on a strong chemical industry.

7 India updates draft national chemical policy: ChemicalWatch Global Risk & Regulation News. https://chemicalwatch.com/18318/india-updates-draft-
  national-chemical-policy [Accessed 22 December 2017]
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS    17

2.1 Issues: developed economies
2.1.1 INCONSISTENT LEGAL FRAMEWORKS
In many developed economies, such as Australia, the United States, Canada, and until recently the European Union,
chemicals used in consumer products have been regulated under different domestic laws, creating inconsistent and
piecemeal protections. For example, in the United States, the 1976 Toxic Substances Control Act (TSCA) was implemented
to protect humans and the environment from harm from toxic chemicals, however it does not include drugs, cosmetics or
pesticides, which are covered by different laws. This has meant that protections are inconsistent and challenging to assess.

2.1.2 LACK OF CHEMICAL SAFETY TESTING
In addition to insufficiently tested chemicals that enter the global market each year, many chemicals that were in use prior
to legislation being enacted were ‘grandfathered’ and have not undergone any testing. In Australia 40,000 chemicals were
‘grandfathered’ into the Australian Inventory of Chemical Substances8, while 62,000 were included in TSCA in the United
States9. In addition, the long-term effects of new chemicals, such as cancer and hormonal disruption, are not taken into
account in required safety testing.

2.1.3 TRADE SECRETS
Many domestic chemical regulatory frameworks, including Australia and the United States, allow companies to not disclose
all of the chemical ingredients in their products to protect ‘trade secrets’. Although these chemicals are still subject to
national testing requirements, consumers are not able to access and make informed decisions about chemicals in products.
A controversial example is ‘fragrance’, an umbrella term which includes substances found to be allergenic and potentially
toxic to organ systems.

2.2 Issues: developing economies
Lack of regulation and enforcement: in addition to the issues described above, many developing economies across Asia,
Africa and Latin America do not have sufficient basic regulatory frameworks and chemical registration schemes. In addition,
where regulation does exist, the state often does not have the capacity to enforce restrictions and bans.

8 National Toxics Network, (2014) Review of the National Industrial Chemicals and Notification and Assessment Scheme (NICNAS)
  http://www.ntn.org.au/wp/wp-content/uploads/2014/09/NTN-SubmissiondraftRIS2014.pdf
9 Ebnesajjad , S. (2016) TOSCA is an Opera, TSCA can be a Drama, in Chemical Manufacturing Excellence,
  https://chemical-materials.elsevier.com/chemical-manufacturing-excellence/tosca-is-an-opera-tsca-can-be-a-drama/
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 18

2. Understanding the regulatory and
political context continued

2.3 Key topics of concern and controversy
2.3.1 AGGREGATE EXPOSURES AND ‘COCKTAIL EFFECTS’
Due to the ubiquity of chemicals in consumer products, people are often exposed to many substances, multiple times a day.
This is important because many chemicals have different effects based on the amount, duration and frequency of exposures,
and what other chemicals they are combined with. The transformation of chemical behaviour because of combination with
other chemicals has been termed the ‘cocktail effect’. It is consequently insufficient to assess safety based on a single
chemical in a specific setting removed from the influence of other chemicals and environmental factors.

 i     IMPLICATIONS FOR COMPANIES: risk can be decreased by assessing the effects of aggregate exposures and
       probable combinations of chemicals, to determine how the amount of a particular chemical in a product that is applied
      multiple times a day, or with other products, can be modified accordingly.

2.3.2 LOW-DOSE EFFECTS
Traditional approaches to regulatory toxicology follow the axiom that ‘the danger is in the dose’. Tests to determine the toxicity
of a substance assume that substances will always be more toxic at higher doses, and less toxic at lower doses. Consequently,
allowable dose limits are established for many substances that are toxic at high doses. However, emerging research has found
that some chemicals are more harmful at low doses. For example, some EDCs fool the body at low doses into thinking they
are hormones, thus allowing them to disrupt the function of the hormonal system. At higher doses, these same chemicals are
recognised by the body as foreign, and don’t have the same impact.

 i     IMPLICATIONS FOR COMPANIES: substances that are currently allowed at low doses may be banned or require
       disclosure on labels in the future. It is consequently advised that substances found or suspected to have ‘low dose’
      effects are excluded from consumer products.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS              19

2.3.3 REGRETTABLE SUBSTITUTION
Chemicals that are discovered to be harmful to humans or the environment are often replaced by chemicals that have been
inadequately researched, and are later discovered to be harmful in similar or different ways. This problem has been termed
‘regrettable substitution’ and is pervasive in the consumer product industries. One reason regrettable substitution is such
a problem is because each chemical in a product serves a particular purpose. Companies are therefore likely to seek out a
replacement chemical that is structurally and functionally similar to the problematic chemical so they do not need to radically
alter their product formulation.

Two approaches to avoid regrettable substitution are provided below. In many cases, these options should be used in
conjunction with one another.

Option 1: Product Redesign
Where a harmful chemical must be replaced, a ‘best practice’ approach does not involve substituting it with another chemical
that is under-researched, but thinking about how the product could be redesigned to avoid the use of harmful chemicals.

 i    IMPLICATIONS FOR COMPANIES: ‘regrettable substitution’ can be avoided by rethinking how a product’s functions
      could be delivered through a different product design, or even a new product/service system.
      

Option 2: The Six Classes Approach
Certain classes of chemicals have been consistently found to have harmful human and environmental impacts. Although,
not all chemicals in each of these classes have been tested to date, they are closely related and behave in similar ways to
chemicals known to be harmful. Scientists are increasingly advocating that the ‘precautionary principle’ be applied in relation
to these classes of chemicals, and that they should be excluded from consumer products completely. See Figure 2.

 i     IMPLICATIONS FOR COMPANIES: the exclusion of these six chemical classes from consumer products is a crucial
       strategy for avoiding ‘regrettable substitution’. This will also prevent the need for constant reformulation of products,
      and will help safeguard against a loss of community trust in the company.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS            20

3. Evaluation Framework
The evaluation framework involved four broad areas of performance review, as described in the boxed paragraphs below.
Scores and ratings from each area of the evaluation were then aggregated together to form an overall snapshot of each
company, with an overall performance score relating to products and processes (Table 4 and Table 5) as well as a rating for
chemicals of concern (Table 6), rating for ingredient disclosure (Table 7) and a high-level rating for regulatory, reputational
and financial risk (Table 8). Drawing from these four broad areas of evaluation, ISF developed individual recommendations for
de‑risking for each company.

  1a
              Each company’s efforts to eliminate or reduce chemicals of concern in its products were evaluated across
              company product ranges and business processes.

Given the inadequacy of current regulatory frameworks for assessing and restricting hazardous chemicals in consumer products,
ISF have developed a more comprehensive approach to assessing potential human and environmental chemical hazards based
on additional criteria for each of the 21 companies (Table 4). The evaluation criteria outlined in Table 4 below were developed
based on latest scientific findings in addition to existing research into aspects of proactive chemical management strategies
that have been effectively employed by consumer product manufacturers.10 This gave an indication of what was possible, the
challenges faced by companies, and key elements of best practice models.

Table 4: Product responsibility performance evaluation criteria

  Criteria                 Components

  Business operations

  Corporate strategy       Explicit commitment in company strategic plans and policies to exclude chemicals from products
                           that are hazardous to humans and the environment

                           Employs a company-specific or industry Restricted Substances List to determine chemical
                           exclusions for products

                           Regularly evaluates and reports on progress towards chemical management targets, including
                           chemical phase outs

                           Demonstrates commitment to responsible chemical management across all business areas,
                           subsidiary companies and global regions of operation

  Product                  Procedures are in place to evaluate the potential human and environmental impacts of chemicals
  development              considered for use in all new products
  processes
                           Product design processes involve an evaluation of potential impacts of chemicals on humans and the
                           environment across the entire lifecycle of products, including implications for recycling and disposal

  Supply chain             Hazardous chemicals are restricted in the production process, or managed and disposed of
  management               responsibly at all stages of the supply chain

                           Company requires suppliers to comply with proactive chemical management processes, and
                           evaluates their compliance

10	Scruggs, C.E., Buren, H.J.V. (2016), “Why Leading Consumer Product Companies Develop Proactive Chemical Management Strategies”,
    Business & Society, Vol.55 (5), pp. 635-675.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                                 21

  Criteria                     Components

  Leadership                   Works with government, industry and scientists to develop and progress voluntary standards and
                               tools to reform the industry and supply chain
                               Internally runs or supports Green Chemistry initiatives
  Consultation                 Regular benchmarking for chemical safety of products is performed against competitors
                               Has an established process for consulting in-house experts or third parties for assistance with
                               hazardous chemical management
                               Has an effective mechanism to engage with customer feedback around chemical concerns
                               and restrictions
  Product attributes
  Safe materials               All relevant user scenarios and risks are considered when assessing the potential for a chemical to
                               cause harm in a product
                               Products do not contain chemicals that are known or suspected to be harmful to consumers
                               Processes are in place to re-evaluate product formulas when chemical safety concerns are raised
  Communication                Company discloses all product ingredients on labels or its website
                               Certification has been obtained from a third party requiring all product ingredients to be
                               publicly available
                               Procurement policy requires suppliers to disclose information about the production and use of
                               potentially hazardous chemicals
                               Provides training and other resources to suppliers about hazardous chemical management
  Promotion of                 Rethinks product design and production rather than substituting individual chemicals when
  broader chemical             hazardous chemicals are identified in products
  avoidance                    Develops products that remediate chemicals or promote low chemical exposure in the
                               broader environment.

  1b
                Product responsibility efforts were scored based on evidence provided in public documents, surveys,
                written responses and interviews.

Companies’ efforts in product safety and responsibility were assigned scores for each of the evaluation criteria in Table 4. The
scoring system shown in Table 5, was modelled on the Sustainable Packaging Report11 completed by ISF, which provides a
simple way for readers to understand why companies scored high or low in particular actions. Criteria scores (e.g. ‘Corporate
Strategy’) were calculated by a structured process of selecting the highest score from the three information channels (public
documents, survey/written response and/or interview) for each criteria component (shown in Table 4). The overall company
scores were then calculated by averaging the scores across each criterion and assigning an overall level of performance
(Table 5).

11 Kelly, S., Lewis, H., Atherton, A., Downes, J., & Wyndham, J., Giurco, D. (2016): Packaging Sustainability in Consumer Companies in Emerging Markets: Final Report.
   Institute for Sustainable Futures, UTS.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS            22

3. Evaluation Framework continued

Table 5: Product responsibility evaluation scoring table

 Expected performance at each level for selected companies

          Levels of
 Score    performance       Characteristics

   0      No response       No publicly available information

                            Researchers unable to interview a company representative and/or no or insufficient
                            information provided by the company

   1      No action         The company is not aware of the issues or they are not seen as important

   2      Getting started   Some awareness and action

                            Informal commitments

                            Ad-hoc activities

   3      Established       Product responsibility commitments embedded in corporate strategy and processes

                            Responsibility allocated across the company

                            Targets and metrics adopted

                            Suppliers being engaged

   4      Leading           Ambitious targets and metrics adopted

                            Public accountability

                            Company goes beyond compliance

                            Consumer engagement strategy being implemented

                            Good progress achieved for product responsibility and/or outstanding innovation

   5      Chemicals         An ambitious product responsibility strategy guides all business activities including
          management/       procurement
          product
          responsibility    Product responsibility is considered at every stage of product development - design,
          best practice     procurement, manufacture, distribution, etc.

                            Product responsibility is a source of business innovation and competitive advantage

                            Targets have been achieved

                            Continuous improvement strategy in place, not only for the company, but to use corporate
                            leadership position to transform the sector’s practice in collaboration with governments, and
                            civil society
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS             23

   2      Each company’s use of chemicals of concern was evaluated.

Using online tools such as the EWG Skin Deep® cosmetics database and ChemSec’s SINList, as well as the broader scientific
literature, ISF evaluated each company’s use of chemicals of concern. Ratings derived from these sources were finalised by
cross-checking ingredients using the thresholds outlined in Table 6.

Table 6: Chemicals of Concern Ratings and Descriptions

 Chemicals of
 Concern Rating        Description

 HIGH                  Majority of chemicals listed under company name or company products on EWG Skin Deep
                       Database/ChemSec SIN List or other third-party databases are listed as of High Concern.

 MEDIUM                Majority of chemicals listed under company name or company products on EWG Skin Deep
                       Database/ChemSec SIN List or other third-party databases are listed as of Moderate/Medium
                       Concern.

 LOW                   Majority of chemicals listed under company name or company products on EWG Skin Deep
                       Database/ChemSec SIN List or other third-party databases are listed as of Low Concern.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 24

3. Evaluation Framework continued

     3     Each company’s ingredient disclosure was evaluated.

Through interviews with NGOs and academics active in the product responsibility/safety and consumer products sector
regarding chemicals, ISF determined that the level of disclosure a company provides with regard to product ingredients was a
significant indicator of product responsibility efforts. In order to evaluate each company based on a best practice model, ISF
developed a rating based on the Environmental Working Group’s grading system for product/ingredient ingredient disclosure in
its Guide to Healthy Cleaning (Table 7).

Table 7: Levels of Ingredient Disclosure Ratings and Descriptions

 Ingredient
 Disclosure Rating      Description

 POOR                   Product ingredients are listed with very little detail or no details on products or online and/or are hard
                        to find. Chemicals are referred to generically and ingredient lists are not complete.

 INSUFFICIENT           Product ingredients are listed with some detail on products or online. Some chemicals are referred
                        to generically or not listed if used in small amounts.

 GOOD                   Product ingredients are listed in detail on products or online. All chemical names are referred to
                        individually, even if used in very small compositions.

     4     Each company’s regulatory, reputational and financial risk was determined.

Using the product responsibility performance evaluation, chemicals of concern rating and ingredient disclosure ratings
described above, the overall regulatory, reputational and financial risks for each of the selected companies were
determined using the risk reference matrix in Table 8. The reasoning and process for assigning risk is detailed in the boxed
paragraph below.

 i     The determinant for regulatory and reputational risks was the number of chemicals and severity of concern about
       these chemicals within a company’s products. These particular chemicals have been identified in scientific studies
      indicating a potential for human or environmental harm. This approach is intended to mitigate against the risk of
       companies continuing to use chemicals that scientific research has indicated are highly likely to be hazardous. The
       determinant for financial risk is the percentage of product sales that would be affected within the company by
       regulatory or reputational issues, with financial performance and segment sales proportions determined from annual
       and financial reports available online.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS               25

Table 8: Regulatory, Reputational and Financial risk references

                                                                                  Risk level
 Risk type         Determinant                           Low                     Medium                        High
 Regulatory        No. of ingredients          Little disruption          Some disruption           Major disruption to sales
                   of concern/ level of        on sales                   on sales
                   concern                     No-low legal threats       Some legal threats/       Shutdowns/ major
                                                                          minor fines/penalties     penalties/fines
 Reputational      No. of ingredients          No-minor loss of           Some loss of              Major effect on
                   of concern/ level of        customer trust             customer trust            customer trust, may
                   concern                                                                          be unrecoverable
                                               No-little media            Some media coverage       Major media coverage
                                               coverage                   (mostly locally)          (locally/internationally)
 Financial         Size of product             15% of sales
                   categories of concern

More extensive evaluations of company risks could not be provided at this time due to the poor availability of data across
the selected companies.

           Product responsibility performance, ingredient safety, ingredient disclosure levels and risk profiles for

   5       each company were used to determine up to 3 main de-risking areas, probing questions and suggested
           improvements for the short-term (less than 3 years) and long-term (more than 3 years).

The outputs from the four evaluation areas were used to develop recommendations for de‑risking for each company,
highlighting areas of concern and potential actions to be taken in the short and longer term to reduce regulatory, reputational
and financial risk relating to hazardous chemical management.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 26

4. Results Summary

4.1 Overall score results, by company
Figure 3: Overall score results, by company

                    C9 (Ingredients)
       C16 (Adhesives and Sealants)
 C2 (Paints, Adhesives and Sealants)
C10 (Paints, Adhesives and Sealants)
      C4 (Personal Care, Home Care)
                  C3 (Personal Care)
      C5 (Personal Care, Home Care,
        Pesticides and Insecticides)
                   C18 (Ingredients)
                  C1 (Personal Care)
                       C11 (Paints)
                       C15 (Paints)
                C12 (Personal Care)
    C20 (Personal Care, Ingredients)
      C8 (Personal Care, Home Care)
                       C19 (Paints)
                C14 (Personal Care)
      C6 (Personal Care, Home Care,
        Pesticides and Insecticides)
    C17 (Personal Care, Home Care)
      C7 (Personal Care, Home Care,
Adhesives and Sealants, Ingredients)
    C13 (Personal Care, Home Care)
    C21 (Personal Care, Home Care)

                                                   1                   2                 3                 4                   5
                                               No Action        Getting Started     Established         Leading          Best Practice

Figure 3 ranks the companies in order from least to highest average score calculated across the criteria categories, with the
circles representing the average and ‘lozenges’ representing the range of scores achieved across all criteria. All company
performance evaluations were at or below ‘Established’ level. Nine companies were evaluated as ‘Getting Started’ level with
another eight companies evaluated as ‘No Action’. This indicates that there is much progress to be made in moving towards
safe, sustainable and responsible management of chemicals in consumer products across these companies.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                 27

4.2 Overall score results, by assessment criteria
Figure 4: Overall score results, by assessment criteria

Promotion of Chemical Avoidance
                 Safe Materials
                Communication
                   Consultation
                     Leadership
      Supply Chain Management
 Product Development Processes
              Corporate Strategy

                                                   1                   2                  3                 4                   5
                                               No Action        Getting Started      Established         Leading          Best Practice

Figure 4 ranks the companies in order from least to highest average score calculated across the criteria categories, with the
circles representing the average and ‘lozenges’ representing the range of scores achieved across all companies. While many
companies referenced consumer safety, environment and sustainability in their corporate strategies and marketing material, it
was difficult to locate documents that provided evidence of their processes in these areas. Despite statements of commitment
to safety, ‘Safe Materials’ ranked second last, suggesting that many companies continue to manufacture products with
ingredients of concern. The evaluations also suggested little evidence of concerted effort to improve sector/industry standards,
with ‘Promotion of Chemical Avoidance’ receiving the lowest average score out of the eight criteria categories.
CHEMICAL MANAGEMENT FOR CONSUMER PRODUCTS                  28

4. Results Summary continued

4.3 Ingredient disclosure and ‘chemicals of concern’ grades
by company
Table 9: Ingredient disclosure and chemicals of concern

                                                                                                              Ingredient                Chemicals
    Company                                                                    Overall Score                  disclosure                of concern

    C6 (Personal Care, Home Care, Pesticides                                          2.8                       GOOD                     MEDIUM
    and Insecticides)
    C12 (Personal Care)                                                               2.7                       GOOD                       HIGH
    C13 (Personal Care, Home Care)                                                    3.0                       GOOD                     MEDIUM
    C14 (Personal Care)                                                               2.8                       GOOD                     MEDIUM
    C19 (Paints)                                                                      2.8                       GOOD                       HIGH
    C20 (Personal Care, Ingredients)                                                  2.6                       GOOD                       LOW*
    C21 (Personal Care, Home Care)                                                    3.5                       GOOD                     MEDIUM
    C1 (Personal Care)                                                                2.1                  INSUFFICIENT                     LOW
    C2 (Paints, Adhesives and Sealants)                                               1.5                  INSUFFICIENT                    HIGH
    C3 (Personal Care)                                                                1.6                  INSUFFICIENT                    HIGH
    C4 (Personal Care, Home Care)                                                     1.6                  INSUFFICIENT                    HIGH
    C5 (Personal Care, Home Care, Pesticides                                          1.7                  INSUFFICIENT                    HIGH
    and Insecticides)
    C7 (Personal Care, Home Care, Adhesives and                                       3.0                  INSUFFICIENT                    HIGH
    Sealants, Ingredients)
    C8 (Personal Care, Home Care)                                                     2.7                  INSUFFICIENT                    HIGH
    C9 (Ingredients)                                                                  1.1                  INSUFFICIENT                    HIGH
    C10 (Paints, Adhesives and Sealants)                                              1.5                  INSUFFICIENT                    HIGH
    C11 (Paints)                                                                      2.2                  INSUFFICIENT                    HIGH
    C17 (Personal Care, Home Care)                                                    3.0                  INSUFFICIENT                  MEDIUM
    C15 (Paints)                                                                      2.2                       POOR                       HIGH
    C16 (Adhesives and Sealants)                                                      1.2                       POOR                       HIGH
    C18 (Ingredients)                                                                 1.7                       POOR                       HIGH

*    C20 (Personal Care, Ingredients)’s ‘Low’ grade for chemicals of concern should be treated with caution: it was difficult to evaluate due to the
     company’s range of sectors and lack of distinction between these in public documents.

The companies are ranked above according to ingredient disclosure level, as we have found this is the most immediate
area for improvement. Ingredient disclosure on product ingredients and provision of specific chemical names was largely
insufficient across the board, with only seven companies being awarded a ‘Good’ rating for ingredient disclosure. Indian
and Japanese companies fared worst in this area, which may be an indication of the lack of detailed labelling laws in these
countries. Several companies currently satisfy labelling laws and regulatory policies through use of generic ingredient terms
such as ‘fragrance’, ‘parfum’, ‘colourants’ and ‘preservatives’ without the need for specification of chemical names. This is not
considered best practice.
You can also read